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Fundamental Issues In U.S. Taxation of Foreign Entertainers and Athletes
This article is Part One of a two-part article. Part Two will appear in our July 2016 issue.
The United States taxes its citizens and resident aliens on their worldwide income; nonresident aliens are taxed on their U.S. source income and income that is effectively connected with a trade or business in the U.S. These seemingly simple terms ' “citizen,” “resident,” “nonresident,” “U.S. source,” “effectively connected with a trade or business in the U.S.” (well, this last term doesn't seem so simple) ' have spawned volumes of regulations, rulings, cases and articles, the essence of all of which is to determine who is subject to tax in the U.S., and on what.
The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The DOJ's New Parameters for Evaluating Corporate Compliance Programs
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
A Lawyer's System for Active Reading
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.
Bankruptcy Sales: Finding a Diamond In the Rough
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.